NAVY SEAL 1 v. AUSTIN, 1:22-cv-00688

Four active-duty U.S. Navy SEALs (9–25 years’ service) sue challenging enforcement of the DoD COVID-19 vaccine mandate on First, Fifth Amendment and RFRA grounds and seek declaratory/injunctive relief plus restoration of pre-mandate status.
Plaintiffs assert sincerely held religious objections and that refusal will trigger DoD special-operations disqualification, affecting deployment and special pay.
Plaintiffs allege their identities are tied to classified and sensitive operations (including official/non-official cover), and public identification would risk their safety, their families, ongoing/future operations, and national security—exacerbated by modern technologies (facial recognition, social media).
They moved to proceed pseudonymously; the motion was directly referred to the Chief Judge under local rules governing pseudonymous filings and sealing.
The court balanced the presumption of open judicial proceedings against plaintiffs’ security/privacy interests and found plaintiffs carried their burden that anonymity is warranted at this early stage.
Order: motion to proceed pseudonymously GRANTED (may use pseudonyms Navy Seal 1–4); plaintiffs must file real names/addresses under seal within 10 days; defendants are barred from publicly disclosing identifying information except for investigation/defense purposes.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether plaintiffs may proceed anonymously	Anonymity necessary to protect classified operations, personal and family safety, and national security; not mere desire to avoid criticism	Openness of judicial proceedings; heightened public interest when suing the government supports disclosure	Granted: anonymity permitted at this stage as plaintiffs showed concrete security/privacy risks; conditions imposed (sealed disclosure to court; limited defendant use)

In re Sealed Case, 931 F.3d 92 (D.C. Cir. 2019) (articulates presumption of openness and use of James factors when considering anonymity)
In re Sealed Case, 971 F.3d 324 (D.C. Cir. 2020) (reiterates bedrock principle of open proceedings and flexible balancing inquiry)
James v. Jacobson, 6 F.3d 233 (4th Cir. 1993) (provides five-factor guidepost for evaluating requests to proceed anonymously)
United States v. Microsoft Corp., 56 F.3d 1448 (D.C. Cir. 1995) (discusses judicial duty to assess anonymity requests and balance openness against privacy)
Horowitz v. Peace Corps, 428 F.3d 271 (D.C. Cir. 2005) (holds modest privacy interests can outweigh no public interest)
Peary v. Goss, 365 F. Supp. 2d 713 (E.D. Va. 2005) (example upholding pseudonym for a plaintiff with national-security/operational concerns)